SEBI, through Circular HO/38/12/(5)2026-MIRSD-POD/I/6703/2026 dated March 11, 2026, has provided a significant relaxation in certification requirements for Persons Associated with Research Services (PARS) who perform sales and other non-core services. This guide explains the new framework and compliance requirements.
Background
Previous Certification Requirement
Under Regulation 7 of the SEBI (Research Analysts) Regulations, 2014, Persons Associated with Research Services (PARS) were required to obtain certification from NISM by passing the "NISM Series-XV: Research Analyst Certification Examination".
Challenges
Based on feedback from market participants, the existing certification was considered:
- Too Complex: The Series-XV examination was seen as too complex for personnel performing sales and non-core functions
- Not Relevant: The content was not fully relevant to sales and relationship management roles
- Barrier to Entry: The certification requirement created a barrier to entry for personnel in support roles
The New Certification Framework
Lighter Certification Module
SEBI has specified a lighter NISM certification module for PARS who perform sales and other non-core services:
- Module Name: NISM Series-XXV-A: Persons Associated with Research Services (Sales and Other Non-Core Services) Certification Examination
- Reference: NISM Communique No. NISM/Certification/NISM Series-XXV-A: Persons Associated with Research Services (Sales and Other Non-Core Services) Certification Examination/2026/01 dated January 30, 2026
Who is Covered
The lighter certification applies to PARS who:
- Perform Sales and Other Non-Core Services: Personnel performing sales, relationship management, and other non-core functions
- Have Client Contact: Personnel who interact with clients
- Not Directly Associated with Research: Personnel not directly associated or involved in research related aspects
Examples of Covered Personnel
- Sales Staff: Sales personnel
- Relationship Managers: Client relationship managers
- Service Relationship Managers: Service relationship managers
- Other Client-Facing Staff: Other staff who interact with clients
Certification Requirements
For Sales and Non-Core PARS
PARS performing sales and non-core services must:
- Pass NISM Series-XXV-A: Pass the NISM Series-XXV-A certification
- Maintain Validity: Maintain certification validity through timely renewal
For Research-Related PARS
PARS other than those performing sales and non-core services continue to be required to:
- Pass NISM Series-XV: Pass the NISM Series-XV certification
- Maintain Validity: Maintain certification validity through timely renewal
Transition Arrangement
For PARS who have already obtained NISM Series-XV certification:
- No Immediate Requirement: Not required to undertake NISM Series-XXV-A certification immediately
- Renewal Time: Obtain NISM Series-XXV-A certification only after expiry of NISM Series-XV certification validity
Practical Implications
For Research Analysts
RAs should:
- Identify PARS: Identify all PARS and their roles
- Categorize: Categorize PARS into sales/non-core and research-related
- Ensure Certification: Ensure appropriate certification for each category
- Timeline: Ensure compliance within specified timelines
For PARS
PARS should:
- Understand Role: Understand which certification applies to their role
- Prepare: Prepare for the appropriate NISM certification
- Certify: Obtain the required certification
- Renew: Ensure timely renewal
Comparison of Certification Modules
| Aspect | NISM Series-XV | NISM Series-XXV-A |
|---|---|---|
| Target Audience | Research-related PARS | Sales and non-core PARS |
| Complexity | More comprehensive | Lighter module |
| Content Focus | Research analysis | Sales and client service |
| Applicability | Research personnel | Sales and client-facing staff |
Compliance Timeline
Effective Date
The provisions of the circular came into force with immediate effect from March 11, 2026.
Transition Period
For PARS with existing Series-XV certification:
- No Immediate Action: Not required to take immediate action
- Renewal Time: Obtain Series-XXV-A after expiry of Series-XV certification
Best Practices
For RA Compliance
- Review PARS Roles: Review roles of all PARS
- Document Classification: Document classification of PARS
- Track Certification: Track certification status
- Plan Renewals: Plan for timely renewals
For PARS
- Understand Certification: Understand which certification is required
- Prepare Early: Prepare for the certification well in advance
- Maintain Records: Maintain records of certification
- Renew Timely: Ensure timely renewal of certification
Expert Legal Guidance
Anuj Desai & Associates provides expert legal services for Research Analysts on NISM certification requirements. Our securities law experts help RAs understand certification requirements, categorize PARS appropriately, and ensure timely compliance. We assist in developing certification policies, tracking certification status, and responding to regulatory inquiries.